The University System of Georgia (USG) selected Woodard & Curran from numerous bidding firms to perform an environmental audit at its then 36 (now consolidated to 32) campuses statewide, all of which entered into an agreement to participate in the EPA’s self-audit initiative. USG undertook one of the largest university system self-audit programs ever conducted in terms of number of campuses, students, labs, and physical plants. Because of Woodard & Curran’s experience performing other large, multi-campus, system-wide audit programs, this project was completed on time, on budget, and to the satisfaction of the USG and EPA.
IMPLEMENTING A UNIQUE APPROACH
Most university systems that intend to disclose violations under the EPA Audit Policy or a specific agreement with the EPA will hire a consulting company and have the consulting staff conduct the audits. Instead, the USG identified a pool of EHS personnel from its campuses to assist in conducting the environmental audits and engaged Woodard & Curran to provide two intensive multi-day training sessions that trained over 60 EHS personnel. Woodard & Curran then led audit teams comprised of both our staff and USG EHS personnel, which varied in size depending on the campus, and prepared the self-disclosure reports. In order to maintain objectivity in audit findings, USG EHS staff did not audit his or her own campus. One key benefit of using USG personnel to participate in the audits is that every campus in the system now has at least one trained auditor on staff with experience in evaluating environmental issues.
COMPLETING A SUCCESSFUL AUDIT
Woodard & Curran developed auditing protocols, standard auditing procedures and checklists, and an audit-reporting database for the USG. After completion of the audit fieldwork activities, each audit team prepared an audit report to communicate audit findings to the campus. The reports included a description of potential non-compliant practices, in order of importance, along with a summary of the applicable regulations and recommendations to correct each identified deficiency. Woodard & Curran also assisted various USG campuses with the correction of a range of compliance issues and in the development of an environmental management system. Moreover, despite the disclosure of thousands of violations, the EPA levied no fines or economic benefit penalties.